The Courts Catch Up with the Law: Expanding Marital Status Discrimination

By MDCR Complaint Investigations Unit

Law Books
Click for Taylor v. LSI Corp. of America,
796 N.W.2d 153 (Minn. 2011) PDF

On April 13, 2011, in light of the Minnesota Human Rights Act (MHRA) definition of “marital status,” the Minnesota Supreme Court overturned its previous ruling in Cybyske v. Independent School District No. 196, 347 N.W.2d 256 (Minn. 1984) that marital status discrimination requires a “direct attack on the institution of marriage.”  See Taylor v. LSI Corp. of America, 796 N.W.2d 153 (Minn. 2011).

In Taylor, the complaining party (Taylor) was hired by LSI Corporation of America (LSI) in 1988.  In June 2001, she married the president of LSI.  In August 2006, her husband was forced to resign from LSI, effective August 31.  Between her husband’s notice of resignation and his last day of work, LSI terminated her employment.  According to Taylor, LSI stated that it was eliminating her position “due to her husband’s situation . . . and the fact that it was likely [the Taylors] were going to have to relocate,” and because “she would be uncomfortable or awkward remaining employed with [LSI] after Mr. Taylor left [its] employ.”

The district court granted summary judgment to LSI on the grounds that Taylor failed to allege that LSI’s action constitutes “a direct attack on the institution of marriage.”  However, the Minnesota Court of Appeals reversed, concluding that the district court erred by requiring a direct attack on the institution of marriage.

The Minnesota Supreme Court affirmed this court of appeals decision, pointing out that Minnesota statutes did not provide a definition for marital status at the time of the Cybyske decision.  In 1988, the Legislature amended the MHRA to define the term “marital status.”  The subsequent MHRA amendment provides a marital status definition that unambiguously includes protection against employment discrimination on the basis of “the identity, situation, actions, or beliefs of a spouse or former spouse.”  See Minn. Stat. § 363A.03, subd. 24.  The marital status definition extends protection against marital status discrimination to include the identity of the employee’s spouse and the spouse’s situation, as well as the spouse’s actions and beliefs.  The Minnesota Supreme Court concluded that Minnesota law does not require a plaintiff to show that termination was “directed at the institution of marriage” in order to establish a “marital status” discrimination claim.

Thank you co-contributing authors Blong Yang and Meg Stinchcomb.

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